Beruflich Dokumente
Kultur Dokumente
SYNOPSIS
Petitioners sought to declare as null and void ab initio certain deeds of sale of real
property executed by their parents, respondents Leonardo Joaquin and Feliciana Landrito,
in favor of their co-respondents-children and the corresponding certi cates of title issued
in their names. They alleged that the sale of the subject properties impaired their legitime
and that there was no actual valid consideration for the deeds of sale, and even assuming
that there was indeed consideration, the price was grossly inadequate. The trial court ruled
in favor of the respondents and dismissed the complaint. The trial court ruled that
petitioners had no valid cause of action against respondents since there can be no
legitime to speak of prior to the death of their parents. On appeal, the Court of Appeals
a rmed the decision of the trial court. The appellate court ruled that petitioners have no
legal capacity to challenge the validity of the subject deeds since they are not parties
thereto and are not principally or subsidiarily bound thereby.
The Supreme Court a rmed the ruling of the Court of Appeals. According to the
Court, petitioners do not have any legal interest over the properties subject of the Deeds of
Sale. Petitioners' right to their parents' properties is merely inchoate and vests only upon
their parents' death. While still living, the parents of petitioners are free to dispose of their
properties and the sale of the lots to their siblings does not affect the value of their
parents' estate because while the sale of the lots reduced the estate, the cash of
equivalent value replaced the lots taken from the estate. The Court also ruled that payment
of the price has nothing to do with the perfection of the contract. Failure to pay the
consideration is different from lack of consideration. The former results in a right to
demand the ful llment or cancellation of the obligation under an existing valid contract,
while the latter prevents the existence of a valid contract. In the case at bar, petitioners
failed to show that the prices in the Deeds of Sale were absolutely simulated. On the issue
of inadequacy of the price or consideration, the Court did not disturb the ruling of the trial
court that the lots were sold for a valid consideration, and that the respondents-children
actually paid the purchase price stipulated in their respective Deeds of Sale. Said factual
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finding by the trial court is binding on the Court.
SYLLABUS
3.ID.; ID.; ID.; PETITIONERS FAILED TO SHOW THAT THE PRICES IN THE DEEDS OF
SALE WERE ABSOLUTELY SIMULATED. — Petitioners failed to show that the prices in the
Deeds of Sale were absolutely simulated. To prove simulation, petitioners presented
Emma Joaquin Valdoz's testimony stating that their father, respondent Leonardo Joaquin,
told her that he would transfer a lot to her through a deed of sale without need for her
payment of the purchase price. The trial court did not nd the allegation of absolute
simulation of price credible. Petitioners' failure to prove absolute simulation of price is
magni ed by their lack of knowledge of their respondent siblings' nancial capacity to buy
the questioned lots. On the other hand, the Deeds of Sale which petitioners presented as
evidence plainly showed the cost of each lot sold. Not only did respondents' minds meet
as to the purchase price, but the real price was also stated in the Deeds of Sale. As of the
ling of the complaint, respondent siblings have also fully paid the price to their
respondent father.
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4.ID.; ID.; ID.; NO REQUIREMENT THAT THE PRICE BE EQUAL TO THE EXACT VALUE
OF THE SUBJECT MATTER OF THE SALE. — Petitioners failed to prove any of the instances
mentioned in Articles 1355 and 1470 of the Civil Code which would invalidate, or even
affect, the Deeds of Sale. Indeed, there is no requirement that the price be equal to the
exact value of the subject matter of sale. All the respondents believed that they received
the commutative value of what they gave. Moreover, the factual ndings of the appellate
court are conclusive on the parties and carry greater weight when they coincide with the
factual ndings of the trial court. This Court will not weigh the evidence all over again
unless there has been a showing that the ndings of the lower court are totally devoid of
support or are clearly erroneous so as to constitute serious abuse of discretion. In the
instant case, the trial court found that the lots were sold for a valid consideration, and that
the defendant children actually paid the purchase price stipulated in their respective Deeds
of Sale. Actual payment of the purchase price by the buyer to the seller is a factual nding
that is now conclusive upon us.
DECISION
CARPIO , J : p
The Case
This is a petition for review on certiorari 1 to annul the Decision 2 dated 26 June 1996
of the Court of Appeals in CA-G.R. CV No. 41996. The Court of Appeals a rmed the
Decision 3 dated 18 February 1993 rendered by Branch 65 of the Regional Trial Court of
Makati ("trial court") in Civil Case No. 89-5174. The trial court dismissed the case after it
found that the parties executed the Deeds of Sale for valid consideration and that the
plaintiffs did not have a cause of action against the defendants.
The Facts
The Court of Appeals summarized the facts of the case as follows:
Defendant spouses Leonardo Joaquin and Feliciana Landrito are the
parents of plaintiffs Consolacion, Nora, Emma and Natividad as well as of
defendants Fidel, Tomas, Artemio, Clarita, Felicitas, Fe, and Gavino, all surnamed
JOAQUIN. The married Joaquin children are joined in this action by their
respective spouses.
Sought to be declared null and void ab initio, are certain deeds of sale of
real property executed by defendant parents Leonardo Joaquin and Feliciana
Landrito in favor of their co-defendant children and the corresponding certi cates
of title issued in their names, to wit:
c)Thirdly , the deeds of sale do not re ect and express the true intent of the
parties (vendors and vendees); and
d)Fourthly , the purported sale of the properties in litis was the result of a
deliberate conspiracy designed to unjustly deprive the rest of the
compulsory heirs (plaintiffs herein) of their legitime.
Defendants, on the other hand aver (1) that plaintiffs do not have a cause
of action against them as well as the requisite standing and interest to assail their
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titles over the properties in litis; (2) that the sales were with su cient
considerations and made by defendants parents voluntarily, in good faith, and
with full knowledge of the consequences of their deeds of sale; and (3) that the
certi cates of title were issued with su cient factual and legal basis. 4
(Emphasis in the original)
And then there is the argument that plaintiffs do not have a valid cause of
action against defendants since there can be no legitime to speak of prior to the
death of their parents. The court nds this contention tenable. In determining the
legitime, the value of the property left at the death of the testator shall be
considered (Art. 908 of the New Civil Code). Hence, the legitime of a compulsory
heir is computed as of the time of the death of the decedent. Plaintiffs therefore
cannot claim an impairment of their legitime while their parents live.
The plaintiffs are not parties to the alleged deed of sale and are not
principally or subsidiarily bound thereby; hence, they have no legal
capacity to challenge their validity.
Plaintiffs-appellants anchor their action on the supposed impairment of
their legitime by the dispositions made by their defendant parents in favor of their
defendant brothers and sisters. But, as correctly held by the court a quo, "the
legitime of a compulsory heir is computed as of the time of the death of the
decedent. Plaintiffs therefore cannot claim an impairment of their legitime while
their parents live."
With this posture taken by the Court, consideration of the errors assigned
by plaintiffs-appellants is inconsequential.
WHEREFORE, the decision appealed from is hereby AFFIRMED, with costs
against plaintiffs-appellants.
SO ORDERED. 9
In actions for the annulment of contracts, such as this action, the real
parties are those who are parties to the agreement or are bound either principally
or subsidiarily or are prejudiced in their rights with respect to one of the
contracting parties and can show the detriment which would positively result to
them from the contract even though they did not intervene in it (Ibañez v.
Hongkong & Shanghai Bank, 22 Phil. 572 [1912]) . . . .
These are parties with "a present substantial interest, as distinguished
from a mere expectancy or future, contingent, subordinate, or consequential
interest. . . . The phrase 'present substantial interest' more concretely is meant
such interest of a party in the subject matter of the action as will entitle him,
under the substantive law, to recover if the evidence is su cient, or that he has
the legal title to demand and the defendant will be protected in a payment to or
recovery by him." 1 3
Petitioners do not have any legal interest over the properties subject of the Deeds of
Sale. As the appellate court stated, petitioners' right to their parents' properties is merely
inchoate and vests only upon their parents' death. While still living, the parents of
petitioners are free to dispose of their properties. In their overzealousness to safeguard
their future legitime, petitioners forget that theoretically, the sale of the lots to their
siblings does not affect the value of their parents' estate. While the sale of the lots reduced
the estate, cash of equivalent value replaced the lots taken from the estate.
Petitioners failed to prove any of the instances mentioned in Articles 1355 and 1470
of the Civil Code which would invalidate, or even affect, the Deeds of Sale. Indeed, there is
no requirement that the price be equal to the exact value of the subject matter of sale. All
the respondents believed that they received the commutative value of what they gave. As
we stated in Vales v. Villa: 1 9
Courts cannot follow one every step of his life and extricate him from bad
bargains, protect him from unwise investments, relieve him from one-sided
contracts, or annul the effects of foolish acts. Courts cannot constitute
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themselves guardians of persons who are not legally incompetent. Courts operate
not because one person has been defeated or overcome by another, but because
he has been defeated or overcome illegally . Men may do foolish things, make
ridiculous contracts, use miserable judgment, and lose money by them — indeed,
all they have in the world; but not for that alone can the law intervene and restore.
There must be, in addition, a violation of the law, the commission of what the law
knows as an actionable wrong, before the courts are authorized to lay hold of the
situation and remedy it. (Emphasis in the original)
Moreover, the factual ndings of the appellate court are conclusive on the parties
and carry greater weight when they coincide with the factual ndings of the trial court. This
Court will not weigh the evidence all over again unless there has been a showing that the
ndings of the lower court are totally devoid of support or are clearly erroneous so as to
constitute serious abuse of discretion. 2 0 In the instant case, the trial court found that the
lots were sold for a valid consideration, and that the defendant children actually paid the
purchase price stipulated in their respective Deeds of Sale. Actual payment of the
purchase price by the buyer to the seller is a factual nding that is now conclusive upon us.
AcSEHT
Footnotes
1.Under Rule 45 of the Rules of Court.
2.Penned by Associate Justice Artemio G. Tuquero, with Associate Justices Cancio C. Garcia
and Romeo J. Callejo, Sr., concurring.
3.Penned by Judge Salvador S. Abad Santos.
4.Rollo, pp. 29—31.
18.TSN, 14 June 1991, p. 19 (Leonardo Joaquin); TSN, 30 October 1991, p. 6 (Fidel Joaquin);
TSN, 27 November 1991, p. 10 (Felicitas Joaquin Carreon); TSN, 7 January 1992, pp. 5—
6 (Artemio Joaquin); TSN, 31 January 1992, p. 12 (Clarity Joaquin Mendoza); TSN, 11
March 1992, pp. 16—17 (Tomas Joaquin).
19.35 Phil. 769 (1916).
20.Nazareno v. Court of Appeals, G.R. No. 138842, 18 October 2000, 343 SCRA 637.